Massachusetts Office of Technical Assistance & Technology

Transcription

1 Massachusetts Office of Technical Assistance & Technology

2 Designation of TURA Higher & Lower Hazard Substances in Massachusetts Under TURA, the Administrative Council on Toxics Use Reduction can designate up to 10 chemicals per year as Higher Hazard Substances (HHS) They can also designate up to 10 Lower Hazard Substances

3 Designation of TURA Higher & Lower Hazard Substances in Massachusetts These designations allow companies to focus efforts on chemicals that pose the most serious threats to health and safety and the environment.

4 Normal TURA Reporting Criteria Apply Annual use of a listed chemical exceeds the applicable threshold Facility employs the equivalent of 10 or more full-time employees Conducts business activities within specified SIC codes (or equivalent NAICS codes)

5 Higher Hazard Substance Chemical Reductions currently open companies have reported on 509 individual PBT/HHS chemicals at the lower thresholds 63% of these companies have eliminated/reduced one or more HHS/PBT chemicals representing a reduction of 1 million pounds per year of these toxic substances

6 Higher Hazard Substances Designated Higher Hazard Substances effective: year 1. Trichloroethylene (TCE) Cadmium Cadmium Compounds Perchloroethylene (PCE, or PERC) Hexavalent Chromium Compounds Formaldehyde Methylene chloride 2014

7 Higher Hazard Substances Designated Higher Hazard Substances: year 8. 1-Bromopropane (n-propyl bromide) Hydrogen fluoride Cyanide Compounds Dimethylformamide (DMF) ,4 Toluene Diisocyanate Report due July 1, ,6 Toluene Diisocyanate Report due July 1, Toluene Diisocyanate Mixed Isomers July 1, 2018

8 Higher Hazard Substances Note that PBT substances identified by U.S. EPA were automatically designated as HHS in 2007 by TURA. A partial list of these chemicals includes: dioxin and dioxin-like compounds Lead and lead compounds Mercury and mercury compounds Polycyclic Aromatic Compounds (PACs) Benzo (g,h,i) perylene Hexachlorobenzene Polychlorinated Biphenyls (PCBs) Tetrabromobisphenol A Hexabromocyclododecane (HBCD) TURA report due 7/1/2018

9 Lower Hazard Substances This designation does not affect reporting thresholds But it does eliminate the per-chemical reporting fee Reporting and Planning Requirements for these chemicals remains unchanged As of January 2016, 10 chemicals/chemical categories have been designated as LHS They are: iso-butyl alcohol, sec-butyl alcohol, n-butyl alcohol, ferric chloride, ferrous chloride, ferric sulfate, ferrous sulfate (heptahydrate), butyl acetate & iso-butyl acetate

10 Example: Threshold determination new HHS Hydrogen Fluoride (HF) Processing HF: Dilution of 1430 pounds of 70% hydrofluoric acid to 49% hydrofluoric acid for resale would be considered processing 1,001 pounds of HF If 1,430 pounds of 70% hydrofluoric acid is used to manufacture fluoroboric acid, report 1,001 pounds of HF as processed

11 Threshold determination for New HHS Hydrogen Fluoride (HF) Otherwise Use HF: If 2043 pounds of 49% hydrofluoric acid is used in solutions to remove oxides from stainless steel, report 1001 pounds HF as otherwise used

12 Processing or Manufacturing HF from Ammonium Bifluoride or Other Fluoride Salts: When dry ammonium bifluoride (ABF) contacts water, it generates hydrofluoric acid. The hydrogen fluoride derived from fluoride salts (such as ABF) is considered manufactured. (EPA guidance 745-R ) Ammonium bifluoride used (processed) in dry blends for resale are not likely to have reportable quantities of HF

13 Do I trip a reporting threshold for HF? Under TURA, when a given listed substance is introduced into production anywhere at the facility, it is counted only once at the facility level, regardless of how many times that listed substance is used, recycled or reused onsite.

14 Chemical Machining

15 Hydrogen Fluoride Example Example: In the calendar year, 3000 pounds of ammonium bifluoride is consumed in an etching bath Solution: 35% of 3000 pounds manufactures 1050 pounds of HF which exceeds the 1000 pound threshold. The 1050 pounds of HF manufactured is also otherwise used, however it is only reported once at the facility level, and this amount would not be added to other quantities otherwise used

16 Hydrogen Fluoride Example: Solution Manufactured = 1050 pounds Byproduct =?? pounds Processed = 0 pounds Shipped as Product= 0 pounds Otherwise used = 0 pounds

17 Cyanide Compounds Example A 300 gallon copper plating tank operates with 1000 liters of solution. A fresh solution is made up at the beginning of the calendar year with 60 kilograms of copper cyanide and 94 kilograms of sodium cyanide. Over the course of the year, 323 kilograms of copper are consumed from the anode, creating 455 kg of copper cyanide as 323 kilograms of copper are plated from the solution onto steel parts. Also, 25 kg of cyanide salts have been added to maintain tank concentrations due to dragout losses.

18 Object Being Plated Pure Copper 60 Kg of CuCN 94 Kg of NaCN 25 Kg NaCN 323 Kg Cu 455 Kg Cu + CN Kg Cu Copper Cyanide Solution

19 Cyanide Compounds Solution In that case: Form S, Section 1: Facility-Wide Use of Listed Chemical (Cyanide Compounds) c. Manufactured = 455 kg X (2.20 lb/kg) = 1001 pounds of Copper Cyanide d. Processed = 60 kg X (2.20 lb/kg) = 132 pounds of Copper Cyanide e. Otherwise used = (94 kg + 25 kg) = 119 kg x (2.20 lb/kg) = 262 pounds of Sodium Cyanide f. Byproduct = 179 kg X (2.20 lb/kg) = 394 pounds CuCN and NaCN g. Shipped as Product = 0 kg = 0 pounds Form S, Section 2: Materials Balance

20 Cyanide Compounds Example: Solution Manufactured = 1001 pounds Byproduct = 394 pounds Processed = 132 pounds Shipped as Product = 0 pounds Otherwise used = 262 pounds

21 Higher Hazard Substances Trichloroethylene (TCE) Sectors most likely to be processing TCE are: 2899 (Chemical Preparations) 2851 (Paints and Allied Products) 2842 (Polishes and Sanitation Goods) 2869 (Industrial Organic Chemicals)

22 Higher Hazard Substances Trichloroethylene (TCE) Both acute and chronic adverse health effects Opportunities for adoption of alternatives For cleaning aqueous and semi-aqueous systems Eliminate the need for cleaning thru process redesign In adhesives water-based adhesives, hot melts, and high solids adhesives Many alternatives available for use in paints as well

23 Higher Hazard Substances Perchloroethylene (PERC) Metal Degreasing used for a variety of applications, wipe cleaning and vapor degreasing Alternatives include chemical and process changes: Hydrocarbon solvents Aqueous systems Automotive aerosols for brake cleaning Alternatives include chemical and process changes: Heptane, C9-C12 hydrocarbons, toluene, xylene Aqueous aerosolized products

24 Higher Hazard Substances Hexavalent Chromium Compounds Confirmed human carcinogens, mutagens and developmental toxicants with high acute toxicity Metal finishing, metal products and pigments are sectors using these compounds Electricity generation (power plants) on-site releases New filers are likely to be found in SIC 3089 (Plastic Products), Sic 3087 (Custom Compounded & Plastic Resins) and SIC 3471 (Plating and Polishing)

25 Higher Hazard Substances Hexavalent Chromium Compounds In decorative plating applications switching to trivalent chromium is technically feasible The finished product performs similarly The trivalent chromium process is more efficient but requires tighter operational controls Process also tends to be more energy efficient

26 Higher Hazard Substances Hexavalent Chromium Compounds Hard (functional) Chromium electroplating: Some military specs were revised to eliminate the need for hexavalent chromium. Options include: Thermal sprays Nickel-free electroplates and composites Chemical vapor deposition

27 Higher Hazard Substances Hexavalent Chromium Compounds Chromic acid also used for passivation of stainless steel: An alternative includes citric acid Most significant on-going use of hex chrome in MA is chromating processes for aluminum & zinc conversion Industry reps state that these processes can be generally switched to a non-hexavalent process at little or no additional cost The technical perspective is relatively simple Drop-in replacements are frequently available

28 Higher Hazard Substances Hexavalent Chromium Compounds Anodizing is another important application of chromic acid (a hexavalent form) Sulfuric acid anodizing is an alternative Chromic acid is used for plating a metal surface onto plastic Significant because the process requires a relatively high concentration of hex chrome in the solution Plasma etching one alternative

29 Higher Hazard Substances Hexavalent Chromium Compounds Alternatives available for chromium in pigments Include synthetic oxonitrides, iron oxide, bismuth vanadate, organic/inorganic blends using titanium dioxide, mixed metal oxide titanites, iron oxide, rutile zinc compounds, etc.

30 Higher Hazard Substances Methylene Chloride This has both acute and chronic adverse health effects Most common sectors using this chemical are: (pharmaceutical preparations) 2851 (paints and allied products) 2891 adhesives and sealants 2899 (chemical preparations, nec)

31 Higher Hazard Substances Methylene Chloride Other common sectors using this chemical are: 30XX (rubber and plastic products) 33XX (primary metal industries) 34XX (fabricated metal products) 5169 (wholesale trade chemicals and allied products) 7641 (furniture repair)

32 Higher Hazard Substances Methylene Chloride Furniture refinishers use Methylene Chloride to strip paint off of wood products Many alternative chemicals/processes are available Terpene based mixtures, soy based dibasic esters, potassium hydroxide, benzyl alcohol based paint strippers Infrared paint removal systems, steam stripping, and blasting with baking soda, dry ice or wheat starch

33 Higher Hazard Substances Methylene Chloride Metal Degreasing used for a variety of applications, wipe cleaning and vapor degreasing Alternatives include chemical and process changes: Hydrocarbon solvents Aqueous systems

34 Higher Hazard Substances Methylene Chloride Adhesive alternatives include: methyl acetate, ethyl acetate, water-based systems Pharmaceutical preparations and research labs Alternatives: ethyl acetate, benzotrifluoride, 2-methyl tetrahydrofuran, diethoxymethane, dibasic esters

35 Rich Bizzozero